I don’t spend much time criticizing Supreme Court cases, instead opting to follow the late Judge Rich’s advice:

However, it will get litigants nowhere to tell the lower federal courts that the Supreme Court has lost is marbles! … That would cause the Court to lose face and it would be disrespectful …. No lawyer in his right mind would do that.

Nevertheless, Chisum lays out a convincing argument, including a lengthy dissection of the famous Benson quote: “Phenomena of nature, though just discovered, mental processes, and abstract intellectual concepts are not patentable, as they are the basic tools of scientific and technological work.”